[Code of Federal Regulations]
[Title 26, Volume 8]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.669(e)-1A]

[Page 227]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.669(e)-1A  Pro rata portion of taxes deemed distributed.

    (a) If a capital gain distribution is deemed under Sec. 1.669(a)-1A 
to be distributed on the last day of a preceding taxable year and the 
amount is less than the undistributed capital gain for such preceding 
taxable year, then an additional amount is also deemed to have been 
properly distributed. The additional amount is equal to the ``taxes 
imposed on the trust attributable to the undistributed capital gain'' 
(as defined in Sec. 1.665(d)-1A(c)) for such preceding taxable year, 
multiplied by a fraction, the numerator of which is the amount of the 
capital gain distribution allocated to such preceding taxable year and 
the denominator of which is the undistributed capital gain for such 
preceding taxable year. See paragraph (b) of example 1 and paragraphs 
(c) and (f) of example 2 in Sec. 1.669(e)-2A for illustrations of this 
paragraph.
    (b) For the purpose of paragraph (a) of this section, the 
undistributed capital gain of any preceding taxable year and the taxes 
imposed on the trust for such preceding taxable year attributable to 
such undistributed capital gain are computed after taking into account 
any capital gain distributions of any taxable years intervening between 
such preceding taxable year and the taxable year. See paragraph (c) of 
Sec. 1.669(a)-1A, paragraph (c) of example 1 and paragraphs (e) and (h) 
of example 2 in Sec. 1.669(e)-2A.

[T.D. 7204, 37 FR 17156, Aug. 25, 1972]